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HomeMy WebLinkAbout10-3697 Our File No.: 258650 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff CACH, LLC 4340 S MONACO STREET DENVER, CO 80237 Plaintiff, vs. DIANNA M DEIMLER 84 WINTER LN ENOLA, PA 17025 Defendant. FILL., 3;t C'? , `E, ? THE AR`s ,. 2010 JUli -4 FM ; b-3 COSY r.J4. ' 1 v -j"N' PENN'G jL\i ; °a COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: l._.l NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION S 34 S. BEDFORD ST. CARLISLE PA 17013, 717-249-3166 ?t /83-,9.,! ice- .243 4U Our File No.: 258650 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff CACH, LLC 4340 S MONACO STREET DENVER, CO 80237 Plaintiff, vs. DIANNA M DEIMLER 84 WINTER LN ENOLA, PA 17025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is CACH, LLC, 4340 S MONACO STREET, DENVER, CO 80237. 2. Defendant(s) is/are DIANNA M DEIMLER, an adult individual residing at 84 WINTER LN ENOLA, PA 17025. 3. Plaintiff, CACH, LLC, is the Assignee and Successor in Interest of Account #5458001553370390; and said account was issued to Defendant(s) by METRIS, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $4,363.60. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $4,363.60 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AXSO?IATES, P.C. Dated: 5/28/2010 A Law Firm BY: David J. Apotfaker, Esquire Our File No.: 258650 VERIFICATION David J. Apothaker, Esquire hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief. The made subject to the penalties of 18 Pa.C.S.A. 4904 understands that the statements therein are unworn falsification to authorities. David J. Apothakb?Esquire Attorney for Plaintiff DATE: 5/28/2010 CACH, LLC DIANNA M DEIMLER 84 WINTER LN ENOLA, PA 17025 STATEMENT OF ACCOUNT Debtor's Name: DIANNA M DEIMLER Account Number: 5458001553370390 Original Creditor: METRIS Balance Due: $4,363.60 Our File No.: 258650 EXHIBIT "A" 258650 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiff/s: Court Number: CACH, LLC Expiration Date: Type of Action: Civil Action Defendant/s: DIANNA M DEIMLER Serve Upon: DIANNA M DEIMLER Address for Service: 84 WINTER LN ENOLA, PA 17025 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge O Deputize O Certified Mail O Posting Special Service Instructions: * * If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~tittr ~t ~~un6r~1~~ ~~~.. CkRTiGE vF 7HE SMERtP~ FiL~i~ e i ri,~ Jody S Smith Chief Deputy Richard W Stewart Solicitor Cach, LLC vs. Dianna M. Deimler Zd~~ ~`~~~ ~ ~ g~ ~ ~ ~~ ~~t~lP*~S`lL~'~~li~ Case Number 2010-3697 SHERIFF'S RETURN OF SERVICE 06/10/2010 Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on June 10, 2010 at 2042 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Dianna M. Deimler, by making known unto herself personally, at 84 Winter Lane, Enola, Cumberland County Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 SO ANSWERS, ~/,~JyJJ/{"~ June 11, 2010 RON R ANDERSON, SHERIFF MICHAEL BARRIC DEPUTY SHERIFF (c; CountySuite Sheriff, T?Iec7SOtt. !nc CAC41, (.LC v bIAfJNA f~l.1JEllVu.E2 To Whom it May Concern, FILE C~-- r L, - F ~"r~r ~'~ ^ "`~'~RY zoro Jug r ~ ~,~ 2= o ~ Ci.1Ptr :~; _ ~`r, trtill Case # 10-3697 July 13, 2010 I Diamia Deimler am writing this to inform you that as of January 2009 I have lost sight completely in my left eye, I do not have much sight left in my right eye and I am slowly losing what I do have left. As for income the only money I have coming in is my Social Security disability which is in the amt of $843.00 a month, I also have no property. I have been in contact with attorney Dorothy Mott if you have any questions you may contact her at X36-650. o1,3B~ -Go(D5'0 Sincerely, ~~i - Q _ , ~ ~,J`~" Dianna Deimler